IR 05000302/1979027
| ML19254B411 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/03/1979 |
| From: | Joel Jenkins, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19254B393 | List: |
| References | |
| 50-302-79-27, NUDOCS 7909270483 | |
| Download: ML19254B411 (9) | |
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Report No. 50-302/79-27 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, Florida 33733 Facility Name:
Crystal River Nuclear Plant Docket No. 50-302 License No. DPR-72 Inspection at Crystal River Nuclear Plant, Crystal River, Flcrida, and the Company Offices, Florida Power Corporation, St. Petersburg, Florida Inspector:
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H. V. Je ins Date Signed Approved by:
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~A. Ruhlman, Acting Section Chief, Date Signed RONS Branch SUMMARY Inspection on July 9-13, 16, 17, 1979 Areas Inspected
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This routine, announced inspection involved 54 inspector-hours onsite in the area of closeout of inspection items identified in IE report 50-302/79-04.
Results One (1) apparent item of noncompliance (Infraction-failure to follow prc:edures-Paragraph 7.a) and one (1) apparent deviation (Failure to comply with commitments to the NRC) were found.
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DETAILS 1.
Persons Contacted Licensee Employees
- P. Y. Baynard, Acting Manager, Nuclear Support Services G. P. Beatty, Nuclear Plant Manager
- J. C. Clapp, Manager, Quality Program Audits J. Cooper, Jr., Compliance Engineer
- J. C. Hicks, Supervisor Quality Programs
- D. A. Shook, Manager, Nuclear Engineering
- W. R. Watts, Manager, Power Plant Materials Other licensee employees contacted in-ded QA personnel.
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were summarized on July 17, 1979, with those persons indicated in Paragraph 1 above. The item of norcompliance,the deviation, and the unresolved items discussed in paragraphs 7.a, 7.b, and 7.c, respectively, were discussed with the Acting Manager, Nuclear Support Services, who acknowledged the inspector's i ndings without comment.
3.
Licensee Action on Previous Inspection Findings a.
Noncompliance
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(0 pen) Deficiency (302/79-04-04): Failure to provide evaluation statements as required by ANSI N45.2.12 (Draft 4 Revision 2).
The inspector found that the licensee effected retraining on the subject of the evaluation statement as it was specified in procedure QAP 8.0, but that particular statement was not consistent with the Standard. This item remains open until the procedure, QAP 8.0, is brought into alignment with the QA program. This item, in conjunction with two other examples, constitutes a deviation as discussed in Paragraph 7.b.
(Closed) Infraction (302/79-04-06): Failure to establish documentation controls with suppliers as required by ANSI N45.2.13-1976 as committed to by the QA program. The licensee revised QOP 12.0, " Purchases of Quality Material and Services",
to include an attachment for use with procurement packages which specifically requires the supplier to retain procurement documents for no less than seven (7) years and FPC to approve nonconformances associated with all quality orders. This item is closed.
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(Closed) Infraction (302/79-04-07): Failure to record bases for safety evaluations on design changes as required by 10 CFR 50.59. The inspector identified that the licensee appeared to implement his response items satisfactorily in that, (1) the formal letter of guidance to provide general guidelines when executing the safety evaluation on MAR's and PAR's and, (2) AI-400 and CP-114 requiring safety evaluations be routed through the Technical Specification Coordinator were implemented.
(0 pen) Infraction (302/79-04-08): Failure to follow approved procedures as required by 10 CFR 50 Appendix B, Criterion V.
The inspector identified that:
(1) the licensee changed SP-443 (Master Surveillance Plan) to require the Shift Supervisor to review the Jumper Log the first Sunday of each month; (2)
the status of the training program for electricians, mechanics, and I&C technicians is reflected in IE report 302/79-23 to include an update on these training programs; (3) Production Engineering has been requested to develop a procedure to test the emergency diesel generators' alarm circuitry affected by MAR's 77-7-33 and 77-7-33A; and, (4) CP-114-Procedure for Control of Permanent Modification, Temporary Modifications, and Deviations-is revised to require Plac.t Review Committee (PRC) review of all modifications upon completion for complete-ness of testing requirements, etc. The inspector identified that CP-114 was revised and completed but there was a failure by the PRC to review temporary modifications upon completion which is an apparent item of noncompliance as discussed in Paragraph 7.a.
Additionally, the licensee stated that CP-114, Enclosure 2, was revised to require Shift Supervisor action on completing thc safety analyses for jumpers; since CP-114 was not revised as of July 14, 1979, this item, in conjunction with two other examples, constitutes a deviation as discussed in Paragraph 7.b.
Until CP-114, Enclosure 2 is implemented and reinspected by the NRC, this item remains open.
(0 pen) Infraction (302/79-04-09): Failure to distribute a document to and use the document at the location of a prescribed activity as required by 10 CFR 50, Appendix B, Criterion VI and the accepted QA Program (FSAR Section 1.7.6.7.1.f).
The licensee is currently soliciting information to update the
" Crystal River 3 Safety Listing".No estimated completion date is available. This item remains open.
(Open) Infraction (302/79-04-15): Failure to comply to adequate record retention practices as required by the Acceptt; QA Program (FSAR Section 1.7.6.7.1.q).
No review of status was conducted onsite, however, the inspector verified that approxi-mately 35% of the Quality Programs Department audit records have been transmitted to the Plant permanent record file and that the Quality Programs Department is actively engaged in 1048 100
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revisingpolicystatementsandcontrollifgproceduresto assureeachinternalorganization'sreponsibilitiesfor record controls are addressed. Purchasing Department has completed approximately 20% of its file duplications, has ordered fire-resistant record storage cabinets, and has upgraded QOP-10.0 to more completely identify records and update handling procedures. There is another open item identified as a result of the inspector's review of QOP-10.0 and that item is discussed in Paragraph 7.f.
(Open) Infraction (302/79-04-17): Failure to certify inspec-tion personnel and to perform initial and/or periodic evaluations as required by 10 CFR 50, Appendix B, Criterion X and the accepted QA Program (FSAR Section 1.7.6.7.1.j).
The inspector reviewed the revision made to QOP-2.0-Training-and identified no corrective action as stated in the licensee's response to IE Report 302/79-04.
Consequently, this item, in conjunction with two similar examples, constitutes an apparent deviation as discussed in Paragraph 7.b.
b.
Unresolved Items (Open) (302/79-04-01): Failure to include consumable / expendable items on the safety list that are required to accomplish safety-related functions. No licenseeaction was identified in this area. This item is open.
(0 pen) (302/79-04-10):
Inadequate guidance in establishing a method for determining whether or not a modification is safety-related. The inspector reviewed CP-113, Section 4.2.1 which specifir-the documents to be referenced in determining the safety significance of a structure, system, or component.
CP-114 requires in Section 3.2.1 that the Nuclear Techniccl Specifications Coordinator perform the required safety review which provides an additional check on the aspect of safety-related significance. And, for those MAR's generated by engineering in St. Petersburg, CP-114 requires a safety deter-mination to be made. Until Revision 19 to CP-114 is implemented and reinspected during subsequentNRC inspections to provide guidance in handling safety-related determinations for jumpers and temporary modifications, this iten is open.
4.
Unresolved Items Unresolved items are catters about which more information is required to determine whether they are acceptable or may involve noncompliance or devations. One new unresolved item identified during this inspection is discussed in paragraph 7.c.
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Update of Previously Identified Open Items (Closed) (302/79-04-02):
Inadequate measures are provided to establish controls which assure that revisions to Quality Administra-tive Procedures are distributed and entered. The inspector reviewed QAP-2 (Revision 3, dated 6/79), QAP-4(Revision 3, dated 6/79) and QAP-14 (Revision 1, dated 6/79) and verified that measures had apparently been established to issue and track change transmittals for QAPs.
(Open) (302/79-04-11):
Inadequate criteria for determining the need for a 10 CFR 50.59 safety evaluation for a temporary modification.
The inspector reviewed a preliminary draft (Revision 19) to CP-114, Enclosure 2 which provided for 10 CFR 50.59 safety evaluations to be completed for temporary modifications. This item remains open until Revision 19 to CP-114 is implemented and reviewed during subsequent NFC inspections.
(Open) (302/79-04-12):
Inadequate criteria for plant personnel to make safety classification determinations. The inspector reviewed CP-113, Section 4.2.1 which specifies the documents to be utilized to determine the safety significance of a given structure, system, or component. Revision 19 to CP-114 will further address the actions to be taken by plant personnel in handling temporary modifications.
Until Revision 19 to CP-114 is implemented and reviewed during subsequent NRC inspections, this item remains open.
6.
Update of Previously Identified Inspector Follow Items (Closed) (302/79-04-05): Audit checklists not verifying the imple-mentation of all the requirements of the stapdards. The inspector reviewed the record of attendance for a training session within the Quality Departments Program which specifically addressed that audit
checklists were reviewed and that an ongoing maintenance program would ensue to ensure the proper implementation on audit checklists of all the requirements of the standards prior to their next use.
(0 pen) (302/79-04-13):
Inadequate Jumper Log operational information.
The inspector reviewed a preliminary draft of Revision 19 to CP-114 which will establish the requirement for a statement on the jumper log to specify each item's operational significance. Until Revision 19 to CP-114 is implemented and reinspected during subsequent NRC inspections, this item remains open.
(Closed) (302/79-04-14): Failure to provide a rogram to evaluate common or recurring failures.
Page 2, Sectio;.
,.4 of SP-299 has been revised to require failures to be trended against similar failures and these trends are to be reviewed and scrutinized by the Results Engineer.
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l (0 pen) (302/79-04-18): Failure to provide re ired housekeeping and protective caps as required by the accep d QA Program (FSAR Section 1.7.6.7.1m).
An order is being made for sufficient protec-tive caps. Additionally, the inspector reviewed QOP-9.0, Revision 3, dated 4/2/79, and verified that the licensee now provides for a designated QC Specialist to monitor housekeeping and make his reports directly to the Manager of Power Plant Stores.
(Closed) (302/79-04-23):
Inadequate or improperly documented training programs for Compliance Engineers, Mechanics, and Electricians.
This item is closed in regard to this report, but is further addressed in IE Report No. 302/79-23.
7.
Followup Items a.
Failure to Follow Procedure CP-114 During the followup review of CP-114-Procedure for Control of Permanent Modifications, Temporary Modifications, and Deviations-the inspector identified the failure of the Plant Review Committee (PRC) to review completed temporary modification packages for status and adequacy of the completeness of the test and acceptance criteria, etc., as required by CP-114.
CFR 50, Appendix B, Criterion V and the accepted QA Program (FSAR Section 1.7.6.7.1.e) require written procedures to be adhered to in all matters relating to nuclear safety.
CP-114, Page 5, paragraph 3.4.2 requires the PRC to review all modifi-cations for completeness as stated above.
Contrary to the above, safety-related temporary modifications were completed and final records were stored without PRC review of testing completeness.
Examples are:
Jumper No.
System / Location 06-27 ESM CE 3AI, Unit 6A 06-26 AHV 1A Seal Inspection 05-50 NNI Cabinet #4 09-24 Incore Detector The jumpers listed above were safety-related temporary modifi-cations that required testing prior to returning the system to service. This failure to follow procedure CP-114 constitutes an item (302/79-27-01) of noncompliance.
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Failure to Comply with NRC Commitments As the inspector carried out his closeout of outstanding items from IE Report No. 305/79-04, he identified three responses in the licensee's response to the report dated June 15, 1979, that deviated from the commitment as made therein. The three specific commitments made by Florida Power Corporation were:
Item A.
Jumper Record in CP-114, Enclosure 2 was revised
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and that full compliante has been achieved.
Item G.
QOP 2.0, Training, was revised on 4/79 to provide
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better control of training operations.
Item H.
Training was held to address the required evalua-
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tion statement of ANSI N45.2.12 and that full compliance has been achieved.
Contrary to the statements above as they were made in the licensee's response, the inspector identified the following as they actually existed on July 17, 1979:
Item A.
Revision 19 to CP-114, Enclosure 2 was not
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beyond the draft stage.
Item G.
QOP-2.0 was only reviewed claiming the revision
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on 4/79 and no change was made to better control training operations.
Item H.
The statement ured to provide the example for
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the training of personnel to ANSI'N45.2.12 and the required audit evaluation statement was the very same item identi-fied during the original inspection a.2 being contrary to the Standards.
It was a specific statement taken from QOP 8.0, and not consistent with the ANSI N45.2.12 evalua-tion rtatement as required.
Consequently, these three examples of failures to comply with previous commitments to the NRC, constitute a devia-tion (302/79-27-02).
Inadequate Guidance in Plant Manager Concept Approval c.
During his review of CP-114 and the modification packages completed as required by Commission Order datedMay 16, 1979, the inspector identified the inconsistent approval by the Plant Manager of modification concepts. CP-114, Page 8, Section 4.1.3 requires the Plant Manager to sign each MAR for approval of concept of each plant generated MAR. No provision for concept review is made if the MAR is developed offsite.
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-7-Until CP-114 is revised to provide guidance as to a conceptural approval of MAR's generated offsite, this item (302/79-27-03)
in unresolved.
d.
Incomplete Design Package The inspector reviewed MAR's packages that were required by Commission Order dated May 16, 1979, and identified that the documentation to support the test and acceptance criteria necessary to closeout MAR 79-5-70B, Emergency Feedpump Alarm Setpoints, was not included with the design package. All tests were done satisfactorily and checked during the instal-lation and PT 122, but the necessary records were not generated.
Until the test and acceptance criteria necessary to certify MAR 79-5-70B is properly documented, this item (302/79-27-04)
is open.
The Plant Manager committed to a completion date of August 1, 1979, for this item.
Implementation of CP-114, Revision 19
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e.
CP-114, Revision 19 was not approved as of July 13, 1979, but was drafted for review by the inspector, The approval and implementation of this revision are necessary to close out items 08, 10, 11, and 13 of IE Report No. 79-04.
Until CP-114, Revision 19, is implemented and reinspected during subsequent NRC inspections, this item (302/79-27-05) is open.
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The Plant Manager committed to a completion date of August 1, 1979, for this item.
f.
Undefined Procedural Term As part of the response to item 79-04-15, Purchasing Department has revised QOP 10.0 - Maintenance and Control of Records - to require outdated quality records to be deposited into permanent file storage in accordance with P0QAM on an annual basis.
There is, however, no definition of an outdated record as addressed in QOP 10.0.
Until QOP 10.0 is revised to define when a record is outdated and eligible for permanent storage, this item (302/79-27-06) is open.
The Manager-Power Plant Materials committed to a completion date of August 15, 1979, for this item.
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g.
Emergency Diesel Generator Alarm Tests The emergency diesel generator alarm circuitry tests requested of Production Engineering by the site is currently being generated by Production Engineering. However, in order to completely effect the closeout on this subject, the necessary test of alarm circuits must be performed and completed satis-factorily. The Manager, Nuclear Engineering, has committed to a test procedures completion date of August 2,1979.
Until Crystal River Nuclear Plant 3 receives, approves, and satisfactorily completes the test of emergency diesel generator alarm circuits, this item (302/79-27-07) is open.
The Plant Manager has committed to a completion date of September 1, 1979, for this item, providing that accomplishment of all the tests can be done with the plant operating.
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